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   External Privacy Policy

Developed June 2021

 (ABN: 48 612 453 568)

Tikun Oceana Pty Ltd trading as Tikun Australia

1.1 Privacy Policy

This policy highlights our commitment to protecting the privacy of Information provided to us and explains how Tikun Australia collects, processes, and stores your Information: based upon our legal, corporate, analytical, marketing, security, and administration requirements. This policy outlines our intent to use and to whom we disclose your information to. We, us or our means Tikun Oceana trading as Tikun Australia ABN: 48 612 453 568. Tikun Australia complies with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth) and can be obtained from the Office of the Australian Information Commissioner https://www.oaic.gov.au/privacy/the-privacy-act/

Tikun Australia may request and collect Information from you which may be specific to the nature of your relationship and/or interactions with us. Information provided by you may include voluntary contributions of sensitive information. You have the right to choose what information you provide us, however, please note that this may affect our ability to respond to your enquiry. Our preference is to collect Information directly from you, where reasonably possible, through offline and/or online means.

Information collected offline may occur through physical data collection methods inclusive of the following: telephone, email, interviews, and mail-based communications, or they may result from direct interactions with us through events or conferences or through sales representatives for our products. Information collected and processed through online electronic functions is collated from our Tikun Australia website www.tikunaustralia.com.au through our contact form, as well as across our social media channels inclusive of Facebook and LinkedIn.

By accessing or using our website, social media, or communication services, you indicate that you have read and understood this policy and agree that such access or use, and your continued access and use indicates your consent to this policy and the collection, use and disclosure of your Information in accordance with this policy.

1.2 Personal & Sensitive Information

The Privacy Act 1988 (Cth) defines:

Personal information  means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. 

Sensitive information means information or an opinion about an individual’s: racial or ethnic origin, political opinions, or associations, religious or philosophical beliefs, trade union association or memberships , sexual orientation or practices, criminal record, health, or genetic information and some aspects of biometric information.

In this policy, Information means Personal information and Sensitive information and includes Personal Information and Sensitive Information as defined in the Privacy Act 1988 (Cth).

1.3 Tikun Australia's Collection Methods

Tikun Australia will collect the following Information from telephone and in person communications as well as visitors to our website, email, and/or social media channels:

For general communications we collect the minimum amount of Information required inclusive of the following: full name or initials, authorised contact and/or persons full name or initials, phone number, email address consent, enquiry type, and enquiry reason and details. Should your enquiry, request, comment, or complaint be of a more specific nature, we will collect your email as well as additional information (including sensitive information related to your health) to address your enquiry accurately and efficiently as indicated below.

Website and social media platforms serve to engage with visitors to our site and/or social media channels and we will collect information relevant to the nature of the engagements. This may include engagements of a general, business, media, employment, or trading nature in addition to, healthcare provider enquiries, adverse events and reactions, product issues, complaints, and privacy enquiries.

Additional personal Information and sensitive Information is collected in the following situations. 

We will collect the company position for the enquirer as well as request the submission of an appropriate proposal for business, export, or partnership enquiries via email info@tikunaustralia.com.au.

Request and collect information to verify your authority to provide or request access to a person’s Information.

Request and collect the professional registration number of healthcare providers, company name as well as a description of their health practitioner type.

In special situations or serious safety issues, adverse reactions and non-serious adverse events we will request and collect the initials, date of birth or age of the person who experienced the issue, as well as the necessary event information, sensitive information and/or other medical history or medicine history for us to establish the occurrence of incidents of an adverse nature.

Notifications of product issues will require us to collect information about the product used as well as the issue and/or complaint.

Collect explicit consent including your signature to contact your healthcare provider at your request to aid, through the provision of information and educational materials.

Corporate marketing and/or promotional events; we will request and collect the address and post code of applicants.

Collect and hold employment related documents including resume, cover letter, qualifications and/or employment references submitted to us.

1.4 We use your personal Information and sensitive Information for  

As a manufacturer our primary business function is that we cultivate and manufacture cannabinoid medicines, and we collect and use your Information to perform essential business functions which may include the following:

legitimately address your general enquiries, questions and complaints submitted to us from any persons, administrative, reporting and record-keeping functions to documented communications between any persons who engages with Tikun Australia.

So, we may address specific product related enquiries, fulfil requests for information from Healthcare providers and/or in special circumstances public.

We may use your Information to continue to perform core business functions relating to reporting, satisfying our compliance responsibilities, administrative, media and marketing, research, quality assurance and security purposes.

To provide corporate communications and/or updates in relation to Tikun Australia or carry out corporate promotions.

Professional registration details are used to verify healthcare providers as per our legal requirement, maintaining corporate and administrative functions.

Pharmacovigilance reporting requirements: Information collected about circumstances of an adverse nature is for our assessment purposes; following identification of a significant safety issue or serious adverse reactions, we are required to comply with our legal obligations and to perform mandatory reporting of these events to Government bodies such as the Therapeutic Goods Administration. Information collected concerning non-serious adverse events or reactions will be retained for business, administrative and quality purposes.

Information concerning product issues is used for business improvement, quality assurance and/or reporting purposes to the Therapeutic Goods Administration.

We hold employment information provided to us for purposes relating to human resources including responding to enquiries about employment, candidate consideration during recruitment drives and for notification or consent to continue holding your Information.

To seek your approval if we intend to disclose your information to third parties other than as specified below or use it for purposes other than specified above.

1.5 We may disclose your personal Information and sensitive Information to the following and/or third parties

Essential business practices may result in your Information being disclosed to employees, contractors, or consultants of Tikun Australia including anyone reasonably employed by these contractors, and subcontractors, as well as external companies required to provide professional services of a financial (audit), legal, taxation, insurance, research and development or investment nature.

For the purpose for which it was collected.

We may disclose your Information for corporate and legal reasons such as sale or rebranding of our entity or broadening of our entity.

To comply with our legal obligations for verification of professional registration details through Ahpra and the maintenance of corporate and administrative functions.

Mandatory pharmacovigilance reporting of adverse event or reactions to the Therapeutic Goods Administration as well as our obligations relating to our business, quality, security, and administrative purposes.

Reporting of product issues and updates or notification of product recall to the Therapeutic goods Administration and to consumers.

Tikun Australia uses a variety of third-party service providers to carry out our core business functions daily. Collectively these service providers are essential for the effective functioning and maintenance of our website, providing trackability of data through our website for statistical, analytical and security purposes, as well as generation of Tikun Australia’s online cookie statement.

We use CRM management software for holding and storage of all interactions including personal and sensitive information. Voluntary Information submitted through our social media channels (Facebook and LinkedIn) is retained within these sites, unless a requirement exists for Information to be processed and stored in our CRM application, resulting from business, statistical, legal and/or administrative requirements.

Tikun Australia may disclose for use your de-identified information to third parties; inclusive of Tikun Olam and its related entities globally for purposes including corporate, statistical, quality and research related purposes. Tikun entities or third-party service providers may be located nationally or globally and enquirers acknowledge and consent that Tikun Australia is not required to legally ensure that these entities comply with the Australian Privacy Act 1988 (Cth).

Tikun Australia will be required to disclose your Information where it is stipulated by law or upon governmental request.

For any other purpose with your express consent.

1.6 Holding and/or storage of personal Information 

Information collected through physical means may be either held or stored in paper-based records. Electronic and certain physical records may be processed and transferred to our third-party CRM management software for holding and storage of interactions, documentation and Information which was collected for the above purposes.   

1.7 Sending Information overseas 

We may disclose your information to some service providers such as technology or data storage providers that may be located overseas including Israel, Canada, the United States of America, the United Kingdom, the Philippines, India and other countries or jurisdictions depending on the nature of the services those recipients provide to us.

If we disclose Information to overseas recipients, we will take reasonable steps to ensure that such recipients do not breach the Privacy Act and the APPs unless:

The overseas recipient is subject to a law that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way the APPs protect the information, and


There are mechanisms available for you to access to take action to enforce that protection of law.

However, you acknowledge that, by agreeing to the disclosure of your Information to these third parties operating outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas third parties' compliance with the Act (including the privacy principles) in relation to your personal information and we will not be liable to you for any breach of the Act by these overseas third parties and on this basis you consent to such disclosure.

1.8 Cookies 

Tikun Australia’s website (www.tikunaustralian.com.au) uses a variety of cookies which are small data files for automated user tracking. These data files are stored on the browser of the device of anyone who visits our website. Our site may also use incorporated technologies inclusive of Google Analytics, Showit, Yoast SEO and Cookiebot. Data tracking allows us to perform statistical analysis on gathered data, leading to improvement of our website to provide an improved visitor experience.

Data collected enables us to establish the following:

Internet protocol (IP) addresses

Browser information

Internet Service Provider

Website from which you accessed our website

Mobile device or alternative device connection data

Visitor activities inclusive of tracking the date and time our website is accessed, monitor the quantity of visitors to our site and to determine whether visitors are new or returning to our site or social media channels.

User engagement, tracking of how visitors use our website; identification of popular content or specific pages, and the time spent on each section or page.

Search engine results and traffic flow to our marketing/media sites.

Tikun Australia collects and stores this de-identified data for business improvement relating to marketing and media, security, and statistical purposes.

You can independently manage your cookies settings through your browser options. Customisation allows you to be alerted to cookies which may be encountered when entering websites, to provide you with a choice to retain certain types of cookies from specific websites or to block all cookies regardless of how this might affect your browsing experience. Further information can be found at https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising/




Table 1: Displays Cookies used by the Tikun Australia website www.tikunaustralia.com.au

1.9 Tikun Australia protection measures 

Your Information is protected by various electronic, procedural, and physical safeguards. Tikun Australia uses commercially developed and tested software applications that incorporate encryption mechanisms to secure your stored information. Our internal policies and procedures ensure that your Information is only made available to approved staff or third parties for approved purposes. We train our staff to handle your Information appropriately. 

1.10 Tikun Australia's use of third-party service providers 

Where a service provider holds your information, for continued protection of your Information, generally we require those third parties to adhere to at least the same standards of information security and confidentiality outlined in this policy. We verify their commitment by reviewing their privacy policies.

Service providers often rely on other entities to support their systems and services and we do not control how they manage your information. By approving the sharing of your Information with third parties or service providers, you agree that Tikun Australia is not liable for failures within the third-party systems or procedures to safeguard your information.

1.10.1 Tikun Australia's destruction practices 

Information provided to Tikun Australia through offline means will be processed and stored electronically with the physical record confidentially destroyed via shredding and burning. All electronic Information is retained for a minimum of 7 years at which point it may be stored, archived or permanently de identified. Certain personal and/or sensitive information will be stored by Tikun Australia indefinitely, as determined by our legal requirements in relation to pharmacovigilance and medicine safety activities and/or for our companies’ requirements. 

1.11 Tikun Australia's response to suspected data breaches 

Information data breaches may result from of a failure of software or electronic system protection mechanisms, procedural or physical safeguard failures. Should a breach be identified, in accordance with the Privacy Act 1988(Cth), Tikun Australia will take the necessary steps to notify you of any breaches that may impact the security and confidentiality of your Information.

Further, Tikun Australia will investigate how such a breach occurred and apply corrective and preventative measures to improve the safeguards to protect your Information.

1.12 Disclaimer

All information contained within Tikun Australia’s website and social media channels is strictly intended for educational and informational purposes only and is not intended to be a substitute for medical advice, diagnosis, or treatment advice. Always consult an appropriate qualified healthcare provider regarding any questions or concerns which you may have about your medical condition and for appropriate treatment options specific for your medical condition.

Tikun Australia does not provide medical consultations or medical advice, in viewing our website or social media channels you acknowledge unequivocally it is your personal responsibility to seek appropriate medical advice and/or care as necessary.

1.13 Anonymity & Pseudonyms  

In your dealings with Tikun Australia should you wish not to be identified you have the right to use a pseudonym, except in instances which may inhibit us to carry out required business functions in response to your enquiry, question, comment or complaint. Personal and sensitive information may be required by law to progress an enquiry that requires the involvement of authorised government or legal bodies.

1.14 Access and correction 

The Australian privacy Act 1988 (Cth) details your right to access any Information held by us about you. Tikun Australia will be happy to respond to any requests for information within a reasonable timeframe. Please email privacy@tikunaustralia.com.au for a consent form.

The accuracy of your information is of paramount importance to us and should you find that the information held is out of date or there is a discrepancy, please request a change of details with our friendly team. Please note that prior to updating your information, a personal identification verification process will apply.

Tikun Australia aims to collect information from you directly, on a voluntary basis to ensure this information is accurate at the time of collection. Information provided to us on behalf of another person during offline or online communications will first and foremost be the enquiring persons responsibly to adequately advise the person of their: intent to provide their information, submitted enquiry, gain the patient and/or persons permission to disclose their Information and to advise them of Tikun Australia’s privacy policy and the content contained within.

By providing information on behalf of someone else, you acknowledge that you have sought their approval to provide such information and where this is not the case, you need to inform us so that we can make a conscious decision as to whether we can progress the enquiry further.

1.16 Privacy complaints

Should you like to notify us of an incident relating to the possible breach of privacy or if you would like to submit a question or complaint, you can submit an online form through our website or contact us directly.

Should you have a complaint ensure your communications with us contain sufficient information to allow us to investigate your complaint. Tikun Australia treats all complaints in a confidential manner with the principal intention to resolve your complaint within a reasonable period or as specified by Privacy Act 1988. Should our response be unsatisfactory, you may have a right to make a complaint to the Office of the Australian Information Commissioner at https://www.oaic.gov.au/

1.17 Contact

Should you have any questions in relation to our privacy statement, requests to access and correct your Information please contact Tikun Australia’s Privacy Officer at privacy@tikunaustralia.com.au or via mail to Tikun Australia, PO BOX 686, YANDINA, QLD 4561. 

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